Michigan Compiled Laws

Mich. Comp. Laws § 566.39 (2026)

Claim for relief; extinguishment.

✓ current as of July 2026

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UNIFORM VOIDABLE TRANSACTIONS ACT

Act 434 of 1998

566.39 Claim for relief; extinguishment.

Sec. 9.

A claim for relief with respect to a transfer or obligation under this act is extinguished unless action is brought within 1 or more of the following time periods:

(a) Except as otherwise provided in subdivision (c), if the claim for relief is under section 4(1)(a) or (b) or 5(1), within the time provided in section 5813 or 5855 of the revised judicature act of 1961, 1961 PA 236, MCL 600.5813 and 600.5855.

(b) Except as otherwise provided in subdivision (c), if the claim for relief is under section 5(2), within 1 year after the transfer was made or the obligation was incurred.

(c) If the claim for relief is under section 4 or 5, with respect to a qualified disposition, the time provided in section 5 of the qualified dispositions in trust act.

History: 1998, Act 434, Imd. Eff. Dec. 30, 1998 ;-- Am. 2016, Act 331, Eff. Mar. 8, 2017 ;-- Am. 2016, Act 552, Eff. Apr. 10, 2017

Notes of Decisions

Cited in 17 cases (3 in the last 5 years), 2001–2025 · leading case: Dillard v. Schlussel, 865 N.W.2d 648 (Mich. Ct. App. 2014).

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Dillard v. Schlussel, 865 N.W.2d 648 (Mich. Ct. App. 2014). · cites it 2× “116(C)(7), arguing that challenges to transfers made before June 23, 2005, were barred by the period of limitations set forth in MCL 566.39. 5 Dillard conceded that the statute prescribes a six-year limitations period, *440 but argued that the Schlussels had fraudulently…”

Gold v. Winget (In Re NM Holdings Co.), 407 B.R. 232 (Bankr. E.D. Mich. 2009). · cites it 2× “” See Mich. Comp. Laws Ann. §§ 566.39 (a); 600.”

Nationsbanc Mortg. Corp. v. Luptak, 625 N.W.2d 385 (Mich. Ct. App. 2001). · cites it 2× “§ 566.39; MSA 26.895(9) (emphasis supplied).”

In re Dinoto, 576 B.R. 835 (Bankr. E.D. Mich. 2017). · cites it 2× “(which has a six-year look-back period, see Mich. Comp. Laws Ann. §§ 566.39 (a), 600.”

Wells v. Salmo (In re Select One, Inc.), 556 B.R. 826 (Bankr. E.D. Mich. 2013). · cites it 5× “The Count III Summary Judgment went on to provide that there are genuine issues of material fact with respect to the date of the transfer of the grocery store for purposes of the one-year statute of limitations in Mich. Comp. Laws Ann. § 566.39 (b), leaving that issue for trial.”

United States v. Equip. Acquisition Resource, 742 F.3d 743 (7th Cir. 2014). “14, § 3580 (six years); Michigan, Mich. Comp. Laws Ann. §§ 566.39 , 600.5813 (six years); Minnesota, Minn.”

Finn v. All. Bank, 838 N.W.2d 585 (Minn. Ct. App. 2013). “109A, § 10 (LexisNexis 2005); Mich. Comp. Laws §§ 566.39 , 600.5813, .5855 (2012) (applying six-year statute of limitations with discovery provision that applies to constructive and actual-fraud claims if defendant fraudulently conceals the existence of the claim); Miss.”

Dombrowski v. United States (E.D. Mich. 2020). · cites it 2× “” Mich. Comp. Laws § 566.39 (b); Zervos Grp.”

Shapiro v. Woodberry (Bankr. E.D. Mich. 2020). · cites it 2× “See Mich. Comp. Laws § 566.39 (adopting the six-year statute of limitations period from Mich.”

Gold v. Wall, Sr. (Bankr. E.D. Mich. 2024). · cites it 2× “See Mich. Comp. Laws §§ 566.39 (a), 600.5813.”

Stuart A. Gold, Tr. v. Dorothy E. McLemore Trust (Bankr. E.D. Mich. 2025). · cites it 2× “See Mich. Comp. Laws §§ 566.39 (a), 600.5813.”

John Mighion LLC v. Mht Fam. Props. I LLC (Mich. Ct. App. 2025). · cites it 2× “Generally, exceptions to statutes of limitations are to be strictly construed.”

Show all 17 citing cases →

— Mich. Comp. Laws § 566.39(a) — 4 cases

John Mighion LLC v. Mht Fam. Props. I LLC (Mich. Ct. App. 2025). “Generally, exceptions to statutes of limitations are to be strictly construed.”

Joe Dorr v. Scott Smith (Mich. Ct. App. 2018).

Huntington Nat'l Bank v. David L Steuer Revocable Trust (Mich. Ct. App. 2020).

— Mich. Comp. Laws § 566.39(b) — 1 case

Wells v. Salmo (In re Select One, Inc.), 556 B.R. 826 (Bankr. E.D. Mich. 2013). “The Count III Summary Judgment went on to provide that there are genuine issues of material fact with respect to the date of the transfer of the grocery store for purposes of the one-year statute of limitations in Mich. Comp. Laws Ann. § 566.39 (b), leaving that issue for trial.”

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